Articles and Blogs

On April 4, 2023, the Centers for Medicare & Medicaid Services (“CMS”) released a proposed rule (“Proposed Rule”) that would update Medicare payment policies and rates for skilled nursing facilities (“SNFs”) under the Skilled Nursing Facility Prospective Payment System (“SNF PPS”) for fiscal year 2024. The Proposed Rule also proposes changes and additions to the SNF... READ MORE

On February 4, 2022, the Department of Health & Human Services Office of Inspector General (“OIG”) issued Advisory Opinion 22-02 protecting a children’s hospital’s donor-funded charity program (“Proposed Arrangement”). Under the Proposed Arrangement, the requestor (“Children’s Hospital”) would use funds from two individual donors to establish a restricted endowment fund that would subsidize patient... READ MORE

On September 6, 2019, OIG issued Advisory Opinion No. 19-05 (“the Opinion”) regarding the proposed purchase of real estate from an entity owned and managed, in part, by an excluded individual. The facts that gave rise to the Opinion involved a community health center receiving federal grant funding and Medicare reimbursement which was looking... READ MORE

On January 29, 2019, the Department of Health and Human Services Office of Inspector General (“OIG”) published Advisory Opinion 19-02, which approved an arrangement allowing a pharmaceutical manufacturer to loan smartphones to financially needy patients in order to assist with medication adherence. OIG stated that it would not impose sanctions against the parties for... READ MORE